Outside, above ground, tanks used for storage of flammable and combustible liquids

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

February 5, 1992

Mr. Donald J. Connolley
Central Engineering Department
Akzo Chemicals Inc.
Livingstone Avenue
Dobbs Ferry, New York 10522-3401

Dear Mr. Connolley:

Thank you for your letter of November 6, 1991 requesting interpretations and clarifications of 29 CFR 1910.106 standards on outside, above ground, tanks used for storage of flammable and combustible liquids. Responses to your questions follow. Please accept our apology for the delay in our response.

Question 1: Is the scope of 29 CFR 1910.106 intended to

Handling and Use of Flammable Liquids.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

September 26, 1986

MEMORANDUM FOR:
LINDA R. ANKU
REGIONAL ADMINISTRATOR
FROM:
JOHN B. MILES, JR., DIRECTOR
DIRECTORATE OF FIELD OPERATIONS
SUBJECT:
Handling and Use of Flammable Liquids

This is in response to your memorandum concerning the Paramont Packing Corporation and an on-going inspection by the Philadelphia Area Office. It also confirms discussions between Joe Bode and Walt Siegfried.

The storage and handling of flammable and combustible liquids in Clairol's Stamford warehouse.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

September 19, 1986

Lawrence W. Bierlein, P.C.
Law Offices
P.O. Box 25576
1228 Thirty-First Street, N.W.
Washington, D.C. 20007

Dear Mr. Bierlein:

This is in response to your letter of June 12, 1986, to Assistant Secretary John B. Pendergrass, concerning Clairol, Inc., in Stamford, Connecticut.

Applicability of 1910.106 to Chemical Plants.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

February 13, 1986

Wine being aged is a processing operation and with no fire point, is not a flammable.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

October 14, 1975

Mr. Theodore R. Wellen, Sr.
Safety and Sanitation Engineer
Wine Institute,
717 Market Street
San Francisco, California 94103

Dear Mr. Wellen:

This is in response to your letter dated July 21, 1975, which was forwarded to the National Office for an interpretation.

A complete review of the information provided by your office has been completed by the Occupational Safety and Health Administration, and the following decisions were reached:

The storage of flammable and combustible liquids.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

January 19, 1977

Mr. John W. Thiele,
Manager Occupational Safety and Health
Bristol Myers Company
P. O. Box 182
Easy Syracuse, New York 13057

Dear Mr. Thiele:

This is in reply to your letter of November 23, 1976, concerning the storage of flammable and combustible liquids. This letter will also confirm a recent telephone conversation with a member of this staff.

Flammable and Combustible Liquids.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

December 3, 1976

Mr. Robert Wiedenhoefer, P.E.
Total Comfort of Wisconsin, Inc.
302 North Pewaukee Road
Waukeshaw, Wisconsin 53186

In re: Your letter dated November 3, 1976 OSHA 1910.106 Flammable and Combustible Liquids

Dear Mr. Wiedenhoefer:

Request for a variance from 1910.106.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

October 28, 1987

Mr. Ernest J. Pratt
Building Services Manager
Jostens, Inc.
4119 South 67th Street
Omaha, Nebraska 68117

Dear Mr. Pratt:

This is in response to your letter of June 25, 1987, concerning your request for a variance from 29 CFR 1910.106(d)(4)(iv), and confirms your conversation with Mr. Joseph Bode of my staff.

Flammable and Combustible Liquids.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

September 8, 1976

Mr. Kenneth Koning,
Loss Prevention Consultant
Liberty Mutual Insurance Company
6700 France Avenue, South
Minneapolis, Minnesota 55435

RE: Your letter dated August 6, 1976 - 1910.106, Flammable and Combustible Liquids

Dear Mr. Koning:

In 1910.106(d)(4), Design and construction of inside storage rooms, we find the following:

Are above ground tanks acceptable...in place of diking.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

May 27, 1993

Mr. Wayne Geyer
Executive Vice-President
Steel Tank Institute
570 Oakwood Road
Lake Zurich, Illinois 60047

Dear Mr. Geyer:

This is in response to your letter of December 28, 1992, in which you requested from the Occupational Safety and Health Administration (OSHA) an interpretation on whether the use of double-wall, above-ground tanks is acceptable for secondary containment of flammable and combustible liquids, in place of diking, to meet the requirements of 29 CFR 1910.106(b)(2)(vii). Please excuse the delay in our response.